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EU adopts 11th package of sanctions against Russia. Developments in UK sanctions against Russia and Belarus


The long-awaited 11th package of sanctions against Russia over its invasion of Ukraine was announced earlier today, after EU ambassadors reached a consensus earlier this week. As expected, the package seeks to strengthen existing sanctions and crack down on circumvention.

High Representative Josep Borrell stated that "[t]oday's package increases our pressure on Russia and Putin's war machine. By tackling sanctions circumvention, we will maximise pressure on Russia by depriving it further of the resources it so desperately needs to allow it to pursue its illegal war against Ukraine".

The new sanctions enters into force on the day following the publication in the EU Journal, or on the date of publication (designations). Relevant press statements from the European Commission and the Council of the European Union can be found on their websites.

Among other things, the new measures include:

  • The introduction of a new anti-circumvention tool that allows the EU to restrict the sale, supply, transfer or export of specified sanctioned goods and technology to certain third countries whose jurisdictions are considered to be at continued and particularly high risk of circumvention.
  • An extension of the transit ban of goods and technology which may contribute to Russia's military and technological enhancement or to the development of the defence or security sector, goods and technology suited for use in aviation or space industry and jet fuel and fuel additives, exported from the EU to third countries via Russia.
  • 87 entities have been added to the list of entities directly supporting Russia's military and industrial complex in its war of aggression against Ukraine. These entities will be subject to tighter export restrictions concerning dual use goods and technologies.
  • The list now includes entities registered in China, Uzbekistan, the United Arab Emirates, Syria and Armenia.
  • The list of restricted items that could contribute to the technological enhancement of Russia's defence and security sector now include inter alia electronic components, semiconductor materials, manufacturing and testing equipment for integrated circuits and printed circuit boards, navigational instruments and marine equipment.
  • The suspension of broadcasting licenses have been extended to include five additional media outlets: RT Balkan, Oriental Review, Tsargrad, New Eastern Outlook and Katehon.
  • An extension on the prohibition to transport goods into the EU by road to also include trailers and semi-trailers registered in Russia.
  • A prohibition on access to EU ports and locks to any vessels that engage in ship-to-ship transfers if the competent authorities have reasonable cause to suspect that the vessel is either in breach of the ban on importing seaborne Russian crude oil and petroleum products into the EU, or is transporting Russian crude oil or petroleum products purchased above the relevant price cap. Similar prohibitions apply to vessels transporting Russian crude oil and petroleum products that illegally interfere, switch off or disable their navigation system.
  • An end to the temporary derogation granted to Germany and Poland for the supply of crude oil from Russia through the northern section of the Druzhba oil pipeline.
  • Several new designations on the EU asset freeze list.

New UK Belarus regulations

On 8 June 2023, the UK expanded its Belarus sanctions regime through amendments to the Republic of Belarus (Sanctions) (EU Exit) Regulations 2022 (the press release is available on gov.uk). The amendments entered into force on 9 June 2023, and target additional imports and exports to/from Belarus, expand the criteria pursuant to which persons can be designated under the regime, among other things to allow for designations of family members of sanctioned individuals, and introduce measures to prevent Belarusian media organisations from spreading propaganda in the UK.

Expansion of the designation criteria

Under the amended regulations, OFSI now has the authority to designate individuals and entities holding the right (directly or indirectly) to nominate a director or trustee of an entity affiliated with the Government of Belarus, family members of a sanctioned person or other persons obtaining a financial or other material benefit from a sanctioned person.

Additional import and export restrictions

The amended regulations include additional export restrictions on banknotes, chemical and biological weapons-related goods and machinery-related goods. Further, there are additional import restrictions on gold, processed gold and gold jewellery, as well as cement, rubber and wood.

Obligations with respect to social media services

The new obligations imposed on social media services, internet access services and application stores include a requirement to take reasonable steps to prevent users from accessing online content generated by designated persons.

Amendments to UK Russia sanctions

On 20 June 2023, the UK amended The Russia (Sanctions) (EU Exit) Regulations 2019.

The amendments include an expansion of the "non-governmental controlled areas" of Ukraine, now also including Kherson and Zaporizhzhia oblasts in addition to Donetsk and Luhansk oblasts.

Further, the amendments include an expansion of the "purpose" under which the UK Russia sanctions are imposed, now also including "promoting the payment of compensation by Russia for damage, loss or injury suffered by Ukraine on or after 24th February 2022 as a result of Russia's invasion of Ukraine".


WR Sanctions Alerts provide you with updates on material developments in the country-specific sanctions programmes implemented by the US, the UN, the UK, the EU and Norway. We will not provide updates on mere prolongations, without material changes, of existing sanctions programmes, nor on any listings or de-listings of individuals/entities placed on implemented sanctions lists. Please note that the WR Sanctions Alerts are provided as general information and do not constitute legal advice.

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